## Facts

- Mary Jane Martin was a tenured public school teacher employed by Harrah Independent School District in Oklahoma.
- Her employment contract incorporated School Board regulations, including a continuing-education requirement for teachers with only a bachelor’s degree: five semester hours of college credit every three years.
- Under the Board’s regulation, the stated sanction for noncompliance was withholding scheduled salary increases; Martin refused to comply and lost increases during 1972–1974.
- Oklahoma later required certain teacher salary increases regardless of compliance with the district’s continuing-education policy, limiting the Board’s ability to enforce the requirement through pay.
- The Board notified Martin that her contract would not be renewed for 1974–1975 unless she completed the required coursework by April 10, 1974.
- Martin declined to enroll and stated to the Board that she did not intend to comply.
- The Board found her persistent noncompliance constituted “wilful neglect of duty” under the applicable state tenure statute and voted not to renew her contract.
- After unsuccessful efforts in the state system, Martin sued in federal court alleging Fourteenth Amendment due process and equal protection violations; the district court ruled for the School District, the Tenth Circuit reversed, and the Supreme Court granted review.

## Issues

1. Whether the nonrenewal deprived the teacher of liberty or property without procedural due process under the Fourteenth Amendment.
2. Whether the Board’s shift from withholding raises to prospective nonrenewal was arbitrary in violation of substantive due process.
3. Whether enforcing the continuing-education requirement and nonrenewing the contract denied equal protection.

## Decision

- The Supreme Court reversed the court of appeals and reinstated judgment for the School District.
- Procedural due process was satisfied because Martin received notice of the nonrenewal and a hearing at which she, represented by counsel, contested the Board’s grounds.
- Substantive due process was not violated because the Board’s prospective use of nonrenewal after losing its salary-withholding tool, coupled with an opportunity to comply, was not arbitrary.
- Equal protection was not violated because the Board’s interest in teacher qualifications was legitimate and the continuing-education requirement was rationally related to that interest.

## Legal Principles

- A tenured public employee’s procedural due process claim fails where the employee receives notice of the adverse action and a meaningful opportunity to be heard on the stated grounds.
- Substantive due process review of school-employer employment decisions is highly deferential; a prospective change in enforcement measures in response to changed circumstances is constitutional if rational.
- Absent a suspect classification or fundamental right, educational qualification policies for teachers are reviewed under rational basis and are upheld if rationally related to legitimate governmental objectives.

## Conclusion

The Court held that nonrenewing a tenured teacher for persistent refusal to satisfy a contractual continuing-education requirement, after notice and a hearing, did not violate procedural or substantive due process or equal protection because the policy and its prospective enforcement were rationally related to legitimate educational goals.


Harrah Indep. Sch. Dist. v. Martin, 440 U.S. 194 (1979)